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#1168783 - 04/23/09 03:03 PM
online BSA training ok w the agencies?
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Power Poster
Joined: Apr 2005
Posts: 4,013
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We want to move from "live training". Too many people, too many sessions, overtime, etc. this being said, has anyone opted for the ABA online and, if yes, did you get praises or flak from the regulatory kiddies?
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#1168797 - 04/23/09 03:11 PM
Re: online BSA training ok w the agencies?
Trees
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10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
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If it is a canned program it may not necessarily meet your total training needs. Most regulatory agencies are looking for training on the bank's specific policies and procedures, so unless you also have authoring ability on the on-line courses, it is a little hard to meet those expectations:
Page 38 of the exam manual:
Determine whether the following elements are adequately addressed in the training program and materials:
Coverage of bank policies, procedures, processes, and new rules and regulations.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1168814 - 04/23/09 03:19 PM
Re: online BSA training ok w the agencies?
Trees
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Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
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We use ABA on line and our examiners (OTS) haven't said anything negative. They have different versions for different job descriptions - tellers, lenders, etc.
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#1168815 - 04/23/09 03:20 PM
Re: online BSA training ok w the agencies?
Bagweaver
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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My former employer also uses the ABA on-line training, which as Bagweaver stated has different courses for different job descriptions. They also, however, supplement with live training.
Last edited by Duchess Skittles; 04/23/09 03:20 PM.
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#1168852 - 04/23/09 03:34 PM
Re: online BSA training ok w the agencies?
Skittles
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Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
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I do the live training for our bank, but it's not as involved as it used to be. I now focus on our procedures in face-to-face training.
Last edited by Bagweaver; 04/23/09 03:36 PM. Reason: Can't spell worth a darn!
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Semiretired. Working parttime at Historic Westville as a tour guide.
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#1168875 - 04/23/09 03:50 PM
Re: online BSA training ok w the agencies?
Skittles
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100 Club
Joined: Feb 2004
Posts: 235
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We also use online training and assign canned courses throughout the year covering CIP, OFAC, BSA/AML and FinCEN among others. In previous years we gave a mandatory live BSA/AML training to all employees and 2008 was the first year that we customized a course using our online provider and eliminated the live aspect altogether. Our examiners made sure that we did customize the course to cover our specific policies and procedures and that we also required a test at the end mandatory for all employees. But they were ok with the online training versus the live training because it was customized. We are regulated by the OTS.
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"I shall permit no man to narrow and degrade my soul by making me hate him." ~ Booker T. Washington
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#1168947 - 04/23/09 04:34 PM
Re: online BSA training ok w the agencies?
Miss Banker
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100 Club
Joined: Nov 2005
Posts: 150
on a beach somewhere
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We use BankersEdge program, they have a tool (CAT) that you can purchase so you can customize any course and the test questions. It's a good framework, but allows for ratcheting up or down depending on your risk assessments/areas of vulnerability, etc. Our examiners approve.
Last edited by beachgirlatheart; 04/23/09 04:35 PM.
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#1169098 - 04/23/09 06:23 PM
Re: online BSA training ok w the agencies?
luvflipflops
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Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
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We signed up with EdComm last year for our CBT training and just completed our BSA exam. The examiners were fine with the way we set our training up because we assigned the training based on the job description and basically threw the whole program at the employees. We went with a full blown version of the training as an initation for BSA/CIP/OFAC/CTRs/SARs. However, we have determined that we will have a live training session to go over our BSA policy and how it impacts lenders, tellers, operations, etc.for year 2009 with a shorter CBT training for everyone.
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#1169509 - 04/23/09 11:34 PM
Re: online BSA training ok w the agencies?
NewTooBSA
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Regualtors evaluate training based on its effectiveness, not the medium used. If, as rlcarey says, it incorporates or is supplemented by training on internal processes and procedures, it's fine.
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#1170197 - 04/24/09 08:36 PM
Re: online BSA training ok w the agencies?
Elwood P. Dowd
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Power Poster
Joined: Apr 2005
Posts: 4,013
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OK, very useful answers. Now, suppose you have people use an in-house system, of sorts. Peeps go to a site and download reading mats. then, they download a quiz. they can't take the quiz live. They have to print it and turn it in. is this similar to how you are handling/controlling the tests? Do you see anything flamingly wrong with my scenario as long as the mats and quiz are tailored....the only "live" training we wish to continue is for branch personnel...
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#1170480 - 04/27/09 03:06 PM
Re: online BSA training ok w the agencies?
Trees
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100 Club
Joined: Nov 2004
Posts: 128
Mid-Missouri
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We train mostly on line. I assign 3 to 4 courses per quarter taylored to the employees position; also I assign the annually required courses. The staff downlads the training material and takes the on line quiz and turns the quiz in to me. Prior to giving out asignments I review the material and the quiz; If I feel the quiz is too elementary I will make one of my own for the staff to complete rather than the on-line quiz. I keep a record of the course assignments; who took wich course; and individual test scores. I do just about the same thing for our policies and procedures training. I select the desired traing material from the policy and procedures and email the materila to each employee; I create my own test for this. I report quarterly to the Board what courses were covered, and annually I give the Board q copy of my records. We are FDIC regulated and they have always been complementary of our traing program.
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#1170509 - 04/27/09 03:30 PM
Re: online BSA training ok w the agencies?
Jae
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Power Poster
Joined: Apr 2005
Posts: 4,013
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Hi Jae. Not to nitpik but when you say "takes the quiz online" are staff clicking away online and then submitting the test online as well or are they taking it online then printing and sending to you the test in a paper format??
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#1171165 - 04/28/09 02:17 PM
Re: online BSA training ok w the agencies?
Trees
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100 Club
Joined: Nov 2004
Posts: 128
Mid-Missouri
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Digital University is the on-line training we use. If the test is taken on line the software will produce a certificate with the employees name and test score. I always ask for a printed copy of the certificate and test; I like to go over the test and let the employee know the correct answer for the question(s) they answered wrong. If the employee is more comfortable in printing the test form and marking the answers manually, that is acceptable also. We do not have the cadillac model of Digital University which permitts the trainer to have an electronic record of each staff members training; that's why I ask for a printed copy of the test which is filed in the yearly training documentation.
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#1171310 - 04/28/09 03:58 PM
Re: online BSA training ok w the agencies?
Jae
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Power Poster
Joined: Apr 2005
Posts: 4,013
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OK Jae. For the ones that like to print and complete, has there been anyone (such as an examiner) asking "so how do you know that they didn't ask someone for the answers before sending it to you"? Our method would be rather rustic compared to yours..a step up from classroom but tiny step in terms of controls..but, then again, maybe I am being overly paranoid for nothing.
Last edited by Trees; 04/28/09 03:58 PM.
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#1171490 - 04/28/09 06:05 PM
Re: online BSA training ok w the agencies?
Trees
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Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
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I just wanted to say that when we introduced the CBT for our staff I had to go thru all of the same questions as Trees is asking. My answer was the ethics module that is also included as part of the annual training. Each employee is responsible for their own actions and as adults, should be treated as such. All of our tests are taken online and the results are printed on a report. I dont ask to see the tests nor do I review what was answered. However, we did tell our staff that anyone caught sharing passwords or taking tests for another is grounds for immediate termination.
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#1171662 - 04/28/09 07:36 PM
Re: online BSA training ok w the agencies?
NewTooBSA
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100 Club
Joined: Nov 2004
Posts: 128
Mid-Missouri
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Trees, we are a small operation. The test papers returned to me range in scores from 72% to 100%. I feel like any score under 100% did not involve cheating. Also, as NewTooBSA points out, ethics play a big part. I have never had a State or FDIC examiner question the trustworthiness of any of the scores. Only a couple of employees get regular 100% scores, and they were "A" students in college. I guess what I am saying is I have to have some faith in the staff's honesty; if I can't, I figure we would have more problems than just meeting training requirements.
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#1173898 - 05/01/09 01:48 AM
Re: online BSA training ok w the agencies?
Jae
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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We use Digital University as well, and have been complimented by our examiners twice now since we have had it in place. We too issue 2-4 modules per quarter, depending on the position and level in the bank hierarchy. This is also complimented with topical traingin throughout the year as needed either on a group/branch or individual basis. We have all staff complete the tests online (no paper allowed) which allows the training specialist and myself to monitor progress and results online as well. We require a minimum passing score of 80%, or they must retake the test.
As I have been happy with DU thus far, and they have been extremely easy to work with (i.e. prove where they get their info, clarifyinh bad questions, info, or correcting incorrect info) I am concerned that my staff has become too familiar with the material and thus it may not be as effective as it once was. That said, we are going to explore some other online offerings this summer for our 2010 training program.
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#1174100 - 05/01/09 02:09 PM
Re: online BSA training ok w the agencies?
Trees
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Platinum Poster
Joined: Nov 2004
Posts: 650
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We also have a large audiance with many locations. I was audited recently by FDIC and this examiner suggested that we find ways to make the training specific to the job functions. Some auditors say classroom training is better, some do not like it. So we went the on'line route so every employee received the same message and covered content. Even if they did not do something they were made aware of the requirements. Now they are going in another direction. How do you satisfy them? We are in a no win situation.
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